There are lots of motivations for restructuring a company or group, but it is always vital to ensure to ensure that the transaction is undertaken without triggering unnecessary and unexpected charges.
We have extensive experience advising companies and shareholders on all forms of reconstructions and reorganisations, including demergers and incorporations.
We work closely with clients to understand their key commercial objectives and how we can help to achieve them in the most tax-efficient manner, as well as working with corporate lawyers to ensure our proposed structure is implemented in accordance with the tax planning.
In designing a transaction, we will always focus on reducing and, where possible, eliminating dry tax charges, minimising exposure to stamp taxes, and, crucially, ensuring the commercial goals are met.
As part of the transaction design process, we will ensure that our proposed reconstruction does not impact previous tax planning e.g. avoiding the crystallisation of degrouping charges on a prior transfer of property, and the continued satisfaction share incentive qualifying conditions.